- 6 - petitioner is not entitled to the charitable contribution deduction claimed on his return, and respondent’s disallowance of that deduction is sustained. 2. Schedule C Items The Schedule C included with petitioner’s return shows a net operating loss of $62,884, that, as described above, consists of cost of goods sold, plus various expense deductions. Cost of goods sold is properly taken into account in determining a taxpayer’s net income or loss from business, as are business expenses deductions. Sec. 162(a); sec. 1.162-1, Income Tax Regs. Items that are included in the taxpayer’s computation of cost of goods sold as well as business expense deductions must be properly substantiated. Petitioner did not maintain any books of account for the business. At trial, petitioner suggested that if given more time, he would be able to produce bank records, canceled checks, and retirement plan documents that would support his claim to the items shown on the Schedule C. The record was held open for approximately 90 days to allow petitioner to obtain and submit additional evidence, but he failed to do so. As it turns out, other than petitioner’s vague testimony on the items, nothing in the record supports his claim to the cost of goods sold or deductions claimed on the Schedule C. Respondent’s disallowances of those items are sustained.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011